G.R. No. 56384 - Lecaroz vs. Sandiganbayan

On July 2, 1979, in the municipality of Sta. Cruz, Province of Marinduque, petitioner, then serving as mayor, was alleged to have taken over the operation and control of a gasoline station owned by Pedro Par.
It was charged that petitioner, by exercising his public office, unlawfully assumed control by selling gasoline, issuing invoices and using pieces of yellow pad paper for such sales, and by padlocking the dispensing pump without legal authority.
The original information filed on October 21, 1980, charged him with grave coercion. Subsequently, on November 27, 1980, the information was amended with the insertion of the phrase “by ordering his policemen companions” to specify that his policemen were instructed to effectuate the takeover.

Petitioner filed a motion to quash the information on the ground that the respondent court lacked jurisdiction because the crime allegedly occurred in Marinduque and should be tried before the ordinary courts there.
The respondent court denied the motion, prompting petitioner to file a petition for certiorari seeking relief on three main contentions:

The offense charged was not committed in relation to his office as mayor.
The crime of grave coercion was not among those offenses enumerated in Section 4(c) of Presidential Decree No. 1486, as amended.
The denial of transferring the case to the Court of First Instance of Marinduque was a grave abuse of discretion, particularly because most witnesses were located on that faraway island.

Section 5, Article XIII of the 1973 Constitution created the Sandiganbayan and conferred upon it jurisdiction over criminal and civil cases involving graft and corrupt practices and other offenses committed by public officers related to their official functions.
Section 1 of Article XIII asserts that public office is a public trust, mandating accountability, responsibility, and integrity from public officials.

Presidential Decree No. 1486, Section 4(c), was issued to expand the jurisdiction of the Sandiganbayan to include “other crimes or offenses committed by public officers or employees, including those employed in government-owned or controlled corporations, in relation to their office.”
The case also involved the application of provisions of Presidential Decree No. 1606 (as amended) regarding concurrent jurisdiction with regular courts.
The subsequent amendment by Presidential Decree No. 1861, which provided that cases pending before the Sandiganbayan as of its effectivity remain with it, was critical because the information against petitioner, filed in 1980, predated said amendment.

Whether the Sandiganbayan has jurisdiction over the case despite the offense being charged as grave coercion – an act not directly characterized as a graft or corrupt practice but alleged to have been committed in relation to petitioner’s official duties.
Whether the concurrent jurisdiction between the Sandiganbayan and the regular courts, as provided under PD Nos. 1606 and 1861, favors the respondent court given that jurisdiction was first acquired by the Sandiganbayan.

Whether petitioner's invocation of Section 4(c) of PD No. 1486 conflicts with the constitutional mandate of Section 5, Article XIII.
Whether the denial of the transfer of the case to the Court of First Instance of Marinduque constitutes a grave abuse of discretion, particularly in light of the logistical issues concerning the location of witnesses.

Whether the alleged use of public authority in taking over the gasoline station’s operation properly qualifies as an offense "in relation to his office," thereby justifying the jurisdiction of the Sandiganbayan.